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FACTS OR MYTHS:

THE B ~ G ISSUE OF INCINERATION

Joseph J. SantoIeri, P.E.

Four Nines, Inc. Plymouth Meeting, Pennsylvania

Jack D. Lauber, P.E.

Professional Engineer Latham, New York

Louis Theodore, Ph.D.

Manhattan College Riverdale, New York

For Presentation at:

AWMA - 86TH ANNUAL MEETING Session P-238-01 Denver, Colorado June 13 - 18, 1993

93-W- 105.03

"Facts or Myths: The Burning Issue of Incineration"

Joseph J. Santoleri Four Nines, Inc.

400 Stenton Avenue Plymouth Meeting, PA 19462

Jack D. Lauber Professional Engineer Latham, NY 12233

Louis Theodore Manhattan College

Riverdale, NY 10471

'These comments are strictly those of the author and do not represent those of any government agency.

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FOUR NINES, INC. P.O. Box 701, Conshohocken, PA 19428 (215) 834-0490 FAX (215) 834-1469

A-91-61

v E 0 277 March 21, 1994

Mr. Rick Copland U.S. EPA Standards Development Bureau (MD- 13) RTP, NC 27711

Dear Mr. Copland:

I was fortunate to be in attendance at the recent EPA/ASME seminar on PIC formation and control held at U.S. EPA in Research Triangle Park, North Carolina, on Tuesday and Wednesday, March 8-9, 1994. It certainly was a very worthwhile meeting, and all of us who were there gained from data provided by the speakers as well as from the comments and questions from the audience. Much of this information was directly related to PIC and dioxin formation from the combustion of wastes, whether in an incinerator (HWI, MWI, MSW), boiler, kiln or process furnace. The amount of data that was presented was very useful in updating us on PICs control in the combustion zone, and their reformation in downstream devices, even with the most efficient combustion systems.

The public (which includes all of us) is concerned about statements and reports that have been published in the past by environmental activist groups related to waste combustion; PIC and metd emissiox; m d dimins. One ef their publicatiens w2s "?!aying wit!? Fire" hli "J P. Cesher and J. Thornton - a Greenpeace report published in 1990. Many of their statements regarding incineration of hazardous wastes have been repeated at public forums not only by their representatives, but also persons who hold public office in local, state and federal governmental agencies.

I have enclosed a copy of a paper which I co-authored as a response to their report. As you note from the title, we are presenting the true "FACTS" to dispel the "MYTHS" stated in "Playing with Fire". It would be well to review this so that you are aware of these differences, especially when in public meetings and discussions. I have,,found the public to be knowledgeable with the information in "Playing with Fire" based on the questions and statements made in open meetings. Other groups have taken time to review this publication as well, and in some cases in more detail than we have presented in our paper. These are shown in the reference list and include the Coalition for Responsible Waste Incineration, and the report prepared by Clement International Corporation.

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March 21, 1994 Page Two ..-

I felt that the attendees at this meeting woulb all have an interest in reviewing h i s paper as additional information for your files related to the combustion standards. It will also provide you with "FACTS" thatwe needed to respond to comments and questions resulting from the "MYTHS" in the Greenpeace report.

Sincerely yours,

RMT/FOUR NINES, INC. &pa** sep J. S t e& P.E.

JJS/cb Enclosure

cc wlenc. : Louis Theodore, Ph.D. Jack D. Lauber, P.E.

b: \picsemin. j js/cb/3- 18-94

93-WP-105.03

..- INTRODUCTION

past, poorly controlled incinerators were used to bum such wastes, often polluting the air. The Clean Air Act of 1970 led to the closing of most of these antiquated systems. Certain environmentalists believe that these old, uncontrolled waste incinerators are typical of all incinerators and have erroneously concluded that all waste incinerators were unsafe. Many wastes were landfilled in unsealed landfills whose leachate contaminated groundwater. Burying hazardous chemical wastes in landfills and dumps literally put toxic time bombs in the ground. The tragedy of Love Canal in Niagara Falls, New York is an example of this national problem of improper waste disposal. New U.S. EPA land-ban regulations now prohibit the land burial of volatile organic hazardous waste.

Many critical problems exist today in disposing of municipal, medical and hazardous wastes. In the

A properly designed and operated incineration system has received worldwide scientific acceptance as the best method for destroying and detoxifying many wastes. The U.S. EPA prescribes high efficiency waste incineration as the preferred technology for managing those waste streams that continue to be generated after all technologically feasible source reduction and recycling efforts have been made. Today's state-of-the-art incinerator-air pollution control systems are safe, effective and environmentally sound, with minimal trace emissions that pose negligible health risks. Most state-of-the-art, Best Available Control Technology (BACT) incinerators have emissions equal to those from several automobiles.

Greenpeace issued a report in 1990 entitled "Playing With Fire". As the title suggests, this environmental activist group portrays the government regulators, the U.S. industries that generate waste and the owners and operators of incineration systems as playing games with the fire in these systems. The Greenpeace report was the basis of an appeal by the Utah Chapter of the Sierra Club before the Utah Solid and Hazardous Waste Control Board. A thorough review of the report, considered scientific by its authors, found that the Greenpeace analysis was not conducted according to generally recognized scientific methods and therefore would not yield a credible opinion. This paper highlights Greenpeace's outright errors on subjects such as DRE calcplation$ m&Temissions, trial bum tests, PIC formation, and unbumed hydrocarbons in ash residue from hazaidous waste incinerators. The Greenpeace estimate of metal emissions from incinerators establishes a level at least 650 times greater than found in reported trial bums covering metal emissions testing. The Greenpeace statements regarding hazardous waste incineration are either not based on facts or taken out of context and the facis they use are ouidaid. Tneir data is biased to the extent that any individuai wouid have difficuity mairing a decision about the environmental safety of industrial waste incineration if they only relied solely on this report. The authors representing the regulatory, academic and industrial fields, have pooled their reviews of this unscientific report.

WASTE DISPOSAL METHODS The choice of a hazardous waste disposal methods is limited to three alternatives.

1. Source Reduction 2. Waste Recycling 3. Treatment and Disposal

These three methods are not necessarily exclusive of each other and, more often than not, more than one are used. Source reduction may also be considered Pollution Prevention.' The Fkderal Pollution Prevention Act of 1990 states the preferred solution is for industry to cut down on hazardous waste generation at the source. The emphasis on first reducing waste generation is reflected as important in waste management. Many companies have publicly committed to further reduction in the amount of hazardous waste generated. Annual emission reports from the Chemical Manufacturers Association show that their industry has reduced plant emissions by 40% since 1987. However, the goal of a zero-waste, zero pollution society as advocated by professional "Greens" is technically and economically unachievable; it can only lead to a zero production society. While progress is important and ongoing, those wastes which remain must be managed in a manner that protects the

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e - . environment and human health.'

Many process plants have elected to use recycled wastes as raw materials thereby reducing the costs of waste disposal and improving the overall economics of production. Care must be taken in the selection of the recycled materials to maintain the quality of the products produced. Many states have established recycling agencies to assist companies in the utilization of products as a raw material.

Even with the increased attention on source reduction and recycling, waste residues will remain and these must be treated. One method of treating the remaining hazardous waste residues is incineration, a technology that has improved significantly over the past 40 years.

High efficiency waste incineration is one of the most acceptable solutions for waste management. E.T. Oppelt, Director of the U.S. EPA Hazardous Waste Engineering Research Laboratory, has said, "of all the terminal treatment technologies, properly designed incineration systems are capable of the highest overall degree of destruction and control for the broadest range of hazardous waste streams. Substantial design and operational experience exists and a wide variety of commercial systems are available." He also concluded that "current information suggests that organic combustion by-product emissions identified for incineration of hazardous waste do not represent a significant risk to public health." ' The U.S. EPA requires incinerators be used as BEST DEMONSTRATED AVAILABLE TECHNOLOGY for treating certain waste stream. Incinerators can and do play an essential role in an integrated management system for hazardous wastes.

"GREENS" DREAM IS ZERO PRODUCTION

waste fuels in boilers and process kilns by grossly exaggerating the levels of toxic contaminants emitted into the air.s Their radical agenda proposes that if there were no incinerators, society would stop producing waste and would recyfle everything. This is impossible. An example of this warped thinking can be found in an environmental policy letter written by Peter Bahouth of Greenpeace, where he said "we should not tell people that environmental problems a n be solved by making factories cleaner or imposing corporate environmental taxes to make polluters better neighbors, or by disposing of our society's waste more efEcientiy and faithiuiiy. he red soiuiioii haye to GO wit!: e h i f i g t i q w s t e in the first place, etc.Il6

Greenpeace and other environmental groups attack hazardous waste incineration and the buming of

Paul Horseman of Greenpeace, London addressed the local chapter of the Royal Chemical Society, February, 1991 at HuII University in England and absurdly stated that, "Greenpeace is opposed to incineration even if it achieved eight nines (99.999999%) D E . " "One molecule of waste into the environment is too much," said Horseman. "As long as industry has means to get rid of waste, it will continue to produce waste."'

GREENF'EACE REPORT "PLAYING WITH FIRE" Incineration has unfortunately become increasingly beleaguered by public opposition incited by

environmentalists groups. Greenpeace is one of incineration's most vocal opponents. They have called for a ten year moratorium on siting, permitting or increasing the capacity of all wastb buming facilities including hazardous waste incinerators, cement and aggregate kilns, boilers and industrial fumaces. ,They have made numerous statements about the environmental and health impacts of incinerators. The report Playing With Fire was authored by Pat Costner and Joe Thomton. It was written without any technical engineering basis or participation. It has knowingly presented a biased review of incineration technology to the public. Ms. Costner provided such testimony at hearings before the Utah Solid and Hazardous Waste Control Board on March 17, 1992, in Salt Lake City. The Greenpeace report was used as the basis for an appeal to the State Board, by the Utah Chapter, Sierra Club to disallow a RCRA pennit issued by the State of Utah. Costner admitted that a

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- * . technical review as detailed and researched by the witnesses for the defense would be welcome prior to the next edition. As such, one of the authors of this paper has described the Greenpeke Report as unethical, and unprofessional .*

In presenting its views on incineration in Playing With Fire, Greenpeace neglected a fundamental, but critical stage in the process for evaluating scientific evidence. Scientists rely on a process called "peer review" to ensure that scientific information is reported in a truthful and accurate manner. Peer review involves an evaluation of scientific research by persons who are experts in the field and have not been involved in the work under review. Peer review is often by comment or oral presentations made to professional societies, where scientists can be questioned in public by other scientists; and sometimes by critical review of articles in professional magazines by a committee of peers. Often, the peer review of controversial topics continues long after the original presentation or publication, with open debates and exchanges of letters to the editor of the professional journal.

The objective of this paper is to provide information and comments regarding the Greenpeace report. Much of the material has been drawn from testimony delivered by Joseph Santoleri, serving as an expert witness, at hearings held in Utah for USPCI that received a state permit to construct a commercial hazardous waste incinerator in Clive, Utah (Tooele County). As noted above, the Sierra Club of Utah tried to appeal the permit before the Utah Solid and Hazardous Waste Control Board. The defendants were the Utah Hazardous Waste Permit Authority and USPCI.

REVIEW OF GREENPEACE CLAIMS IN "PLAYING WITH FIRE" REPORT Greenpeace assumes that the average hazardous waste commercial incineratar burns 70 million

pounds of waste per year. Based upon 99.99% destruction and removal efficiency (DRE), the estimated annual release of unburned hydrocarbon wastes in the stack is 7,000 pounds per year; the metals in the stack pGsSjons -403,700 pounds per year; the products of incomplete combustion in stack emissions -- 693,000 pouhds per year; and ash residues of 6,300,000 pounds per year. The following sections will compare the real "FACTS" regarding our research into DRE, metal emissions, products of incomplete combustion, and ash residues.

DRE

0.01 % emissions of unburned wastes. Most waste streams entering a comhercial hazardous waste incinerator may vary from < < < 1 R hazardous organics (soils contaminated at ppb levels) to 100% when fired with liquid organic solvents. On the average, the toxic organics entering incinerators average 25% to 30% of the total stream. Much of the waste stream is inorganic (soil, clay) and water. For example, pharmaceutical waste water streams may contain 95% water.

Greenpeace has assumed that the entire 70 million pounds are hazardous and that this will result in

On the basis of 99.99% minimum DRE, the emissions would be reduced from 7,000 to 2,100 Ib/yr (30% organic). Most trial bums have shown DRE is exceeding Four Nines to levels above Six Nines. Many of the 40CFR264 Appendix VI11 compounds are unstable and low on the Univerbity of Dayton stability list which establishes the difficulty to bum. lo The relationship of DRE to total waste input as proposed by Greenpeace has been reflected in many articles and reports related to siting of new incinerators. The public therefore views emissions on total waste feed rather than total organic waste feed. This fact needs to be brought to public attention along with actual DRE's achieved with today's operating systems.

These estimated emissions are equivalent to 0.24 lbh r of unburned organics, assuming continuous operation. If we constructed a hypothetical 20 mile diameter circle and had light trucks drive around this circle,

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the unburned hydrocarbon emissions from these trucks has been found to average 3.0 grams per mile." The hazardous waste incinerator organic emissions would be equivalent to about &o trucks driving around this circle in one hour. On a current siting permit review, a similar comparison has been made regarding automobile traffic on a 15 mile stretch of highway adjacent to a proposed commercial incinerator facility. Traffic surveys indicate an average of 11,500 automobiles per day. The carbon monoxide emissions from these automobiles will vary from 230 tons to 1735 tons per year, based on the age and condition of the a~tomobile. '~ The expected carbon monoxide emissions from the facility burning 75,000 tons/year (double the average used in Greenpeace's report) is 15 tons/year. The autos will produce from 15 to 115 times more than the incinerator.

Unburned hydrocarbon emissions from these Same autos alone (no truck traffic included) will vary from 138 to 190 tons per year compared to 4.7 tons per year from the incinerator -- a ratio of 29 to 40 times higher. These present day emissions should be of major concem to the environmentalists for protection of human health and the environment.

METAL EMISSIONS

pounds per year, which equates to 0.29% of the waste feed. This value is based on an average metal concentration of all waste streams of 1.5%. In reviewing an EPA report "Partitioning of Metals in Rotary Kiln Incinerators", Greenpeace independently calculated an emission level of metals equal to 19.4% of the metal feed rate. The 19.4% level was not found in the EPA study. The data from the report is listed in Table I.I3

Grqnpeace has estimated the level of metals emissions from an average incinerator at 203,700

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TABLE I . .Metals feed rate and stack emissions.

Input Rate - 140 I b h synthetic waste with nominal feed concentrations.

Concentra- Emission

0.007 3.8-5.8

Ba 50 0.007 2.2

Bi 180 0.0252 41.1

Cd 10 0.0014 56-6 1

Cr 90 0.0126 2.0

cu 500 0.070 15.1

II Pb I 50 I 0.007 I 48.9

II Mg I 17000 I 2.38 I 0.1

St 300 0.042 1.7

,.TokI' 18230 2.5522 19.4%**

% of Total Emission

0.000336

0.000 154

0.010357 35.48

0.00082

0.000252

0.0 1057 36.2

0.003 423

0.00238

0.0007 14

0.029005 100 %

Percent of total feed input discharged from stack

0.029005 f 140 = 0.000207 0.0207% of total feed input

- Percent out - - -

Percent of total metals input discharged from stack - 2.552 Ibhr metal input

Percent out - - 0.029005 f 2.552 - - 0.011365 - - 1.1365% of total metals input

* ** Data available from Carroll Report

"Playing With Fire" calculates the average of the stack emission in % Yf all metals at 19.4%. If actual weight of each metal is calculated as noted above, only 1.13 % of the total metal input exits the stack.

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This again points out the fallacy of the Greenpeace authors in referencing data from a single test program and determining the results to be typical of all hazardous waste incinerators. The scrubber system used at the EPA CRF test facility was a venturi scrubber operating at 30 inches of pressure drop. This is considered an ineffective metals control device by today's standards.

Studies conducted on pollution control systems using the "wet-dry-wet" air pollution controls (spray dryer -baghouse - absorber). have found that stack emissions of metals are generally well below one percent of the metal feed." Field test data on six state-of-the-art facilities report metal emission levels at 0.00045% of the feed rate compared to Greenpeace's report of 0.29%. The true emission of an average plant buming 70 million pounds per year is 315 pounds per year. Their estimate is 647 times higher." These findings are consistent with the findings in the U.S. EPA Regulations for Boilers and Fumaces, dated February 21, 1991 (40CFR Part 260).16 This data is also found in the "Guidance on Metals and Hydrogen Chloride for Hazardous Waste Incinerators" Vol. IV, August 1989 Table 111-8.''

PRODUCTS OF INCOMPLETE COMBUSTION

wastes fed. This is equivalent to 99 times the level of POHCs emitted if operating at only 99.99%. Greenpeace cites hysteresis effects which occur but are unaccounted for during the DRE determination in the trial bum. The basis for the hysteresis comes from pages 12 and 13 of their report where references are made to the published test results of "Mason", "Licis", "Hinshaw", and "SWPC, 1990". The Mason and Licis papers are limited to pilot scale tests on a simulated boiler by Accurex at the EPA Hazardous Waste Engineering Research Laboratory (HWERL). This was a followup to field studies of waste buming in boilers conducted by Accurex for EPA. Results indicated DRE levels of 99.99% or greater for POHCs, but PICs formed in boilers were generally one or two orders of magnitude greater than POHC emissions. However, low PIC emissions accompanied high POHC DREs. The colder surface temperature of tubes exposed to the buming flame envelope iQ a boflef'may cause sooting. The PICs will be discharged during soot blows. Incinerators with an adeqdite skondary combustion chamber (SCC) provide the required temperature, turbulence and residence time required for high efficiency combustion. The SCC also provides sufficient oxygen, thereby reducing PICs to fractions of the POHCs. The environment in the SCC is considerably different than in a boiler. The results of the referenced tests cannot be considered similar to an incinerator operation. Greenpeace interestlngiy noted this in their report in a statement "No tests have been carried out to identify a similar hysteresis effect in incinerators and cement kilns." Yet, the data obtained from these pilot boiler tests became Greenpeace's standard for the average commercial hazardous waste incinerator.

Note that the Greenpeace estimate of PICs are 693,000 pounds per year, approximately 1% of the

METALS AND PICS IN ASH RESIDUES

article cited in Tables 3.4 and Table 4.6." The data from Boegel gives no information on operating temperature or oxygen in the primary chamber. Normally, a two chamber hearth fumace is designed to run with a reducing atmosphere in the primary chamber. Solids are not tumbled as in a rotary kiln and total contact time at the operating temperature is too short to insure organic bumout. The cqllected data is meaningless when comparing this to a fully permitted RCRA incinerator. There was no indication that DRE tests were conducted, no data on temperature, CO and 0, in either chamber. The resulting high level of organics - 2308 ppm - is not unusual under these conditions. Based on this meaningless data, Greenpeace established a level of 2308 ppm organics as the average ash residue from a RCRA incinerator.

A study of a fixed hearth (two chamber) incinerator was cited by Greenpeace. This was Boegel's

Regarding metals in the incinerator ash, Greenpeace shows total metals of 14,577 ppm in the ash. This relates to a total level of 1.5 to 2.2 million pounds of metals released into the environment annually. In this final statement, Greenpeace does not point out that in the referenced text, copper was at a concentration

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- - . of 13,800 ppm. Copper is not considered toxic metal. The total of ten toxic metals was 546 ppm of the remaining metals, only 3.7% of the numbers stated by Greenpeace as an avirage. This, again, is data obtained from one test. A second test showed a 10,393 ppm of total metals. The toxic metals amounted to 795 ppm (7.65% of the Greenpeace reported data). Once again, Greenpeace establishes the industry average for a commercial hazardous waste incinerator from one pilot test.

GREENPEACE REFERENCES TO NSAB REPORT

Advisory Board Reports, 1985 and 1989.19 a, Most of these statements deal with the release of "thousands of PICs", the unknown compounds being emitted, and the use of CO and THC as "surrogate indicators" of stack emissions.

Throughout the report, Plaving With Fire, the authors refer to statements made in two National Science

The excerpts from the NSAB report state the following: "The emissions of PICs is a consequence of any combustion process. Emissions from hazardous waste incinerators contribute a relatively small fraction of the total combustion emissions released into the environment each year. However, with PICs the concerns are the effects on the lQcal environment, not the aggregate national emissions, and the local impacts may vary considerably. "

"Present analytical methods do not allow scientists to identify and measure all compounds in incinerator emissions -- or in many other materials. The best studies characterizing PICs have accounted for about 60% of the mass, some studies have accounted for as little as 1 % of the mass. The available data show that a well designed and operated incinerator does not emit PICs in substantially greater quantities than fossil fuel combustion processes. "Carbon monoxide, being an intermediate in the combustion process and one for which continuous detectors are available, is a candidate for the robust continuous monitor needed for incinerator stack emissions. The rate of oxidation of carbon monoxide is slow relative to that of most organic compounds, and as a consequencq erturbations in combustion conditions, will usually result in an increase in CO concentration well beforelhat of other PICs. CO is expected to persist beyond the completion of combustion of other combustion intermediates. Total hydrocarbons (THC) provides an alternate measure of PICs, because the concentration of THC may better correlate with the large number of PICs which are hydrocarbons."

Another quote from NSAB was stated as follows: According to one analysis, deviations from combustion conditions: "usually are a consequence of rapid perturbation in the incinerator operation resulting from a rapid transient in feed rate or composition, failure to adequately atomize a liquid fuel, excursions in operating temperature, instances where the combustible mixture fraction is outside the range of good operating practice, or inadequate mixing between the combustibles and the oxidant ..... The amount and composition of PICs will depend in a complex and unpredictable way on the nature of the perturbation."'

Greenpeace purposely left out in the space noted with ..... the following: "Modern incinerators are equipped with a large combustion chamber or secondary combustion chamber to minimize the impact of these perturbations. Waste feed management and sound process control systems further reduce or compensate for any adverse impact."20 These clarifying sentences change the effect of the entire paragraph.

Chrostowski and Foster of Clement International Corporation, who reviewed Playing With Fire, concluded that "Greenpeace appeared to bias their analysis and incorrectly interpret and present information as if to support positions they had established previo~sly.~ These environmental scientists also noted that "some of the techniques used by Greenpeace included taking quotes out of context, rounding-off numbers improperly, and omitting a vast amount of research data that did not support its position." "Greenpeace presented the results

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.. - of its work on the environmental impacts of incineration in two articles Report on the Hazardous Waste Incineration Crisis and Playing With Fire. Rather than going through the standard critical peer review process, Greenpeace released these articles directly into the public forum. They further concluded that "Greenpeace makes dozens of open-ended statements that emissions from hazardous waste incinerators cause adverse health impacts, never once providing the necessary scientific analysis to support its claims." A major conclusion cited by these scientists who peer reviewed Playing With Fire, is that "the results of numerous risk assessments have shown that exposure to dioxin or other chemicals at the low exposure levels associated with properly designed, maintained and operated hazardous waste incinerators is unlikely to have adverse consequences for human health."

Greenpeace has also said that a myriad of organic products of incomplete combustion (PICs) are emitted from a hazardous waste incinerator; alleging that large quantities of these unknown toxic PICs could pose significant health hazards. During three trial bum tests of a 30 year old hazardous waste incinerator equipped with an older packed bed scrubber, the presence of over 50 volatile and semi-volatile priority pollutants were evaluated. Generally, there were only trace quantities of a few volatile PICs detected in both the air emissions and scrubber water during these worst case tests, where 50% or greater chlorine content wastes were bumed. The total average dioxin/furan emissions from these tests were far less than 0.7 ngJdscm. 21

Recently, a governmental environmental monitor for this incinerator took representative samples of the scrubber water from this incinerator. Tests were performed for more than 50 volatile and semi-volatile PICs, which indicated that none of these compounds were detectable.P Thus, if these trace toxic contaminants are not found in the scrubber water they would not be in the air emissions from this incinerator. This information was found from studying an older hazardous waste incinerator with an older, marginal air scrubber that is now being replaced inprder to achieve better air pollution control for heavy metals. This information verifies that if the combustion of wash is virtually complete, with carbon monoxide emissions less than 100 ppm, the emissions of trace organic combustion products, PICs, would be non-detectable and of no real concern to public health and the environment.

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errors, has reported material from the literature which is outdated and out of context, and failed to provide any of the fully documented material in the literature that did not support its position. The data was biased to such an extent that an informed decision by lay persons could not be made about the environmental safety of industrial waste incineration. Their report is being used by many, including elected officials as the true story of incineration. We have included comparisons of incinerator emissions to automobile and light truck emissions to point out the minimal impact of these facilities on existing emissions. We have attempted to present the real "FACTS" concerning incineration, all of which are well documented, and have exposed the Greenpeace "MYTHS". The negative impact on public opinion created by the "Greens" is intellectually dishonest and a public diservice. While they attempt to occupy the moral high ground, they should be exposed at every opportunity. ,'

The nation's waste management problem is a serious subject. Attempts to prevent the use of the proper

The analysis that Greenpeace presents in the report Playing With Fire contains numerous technical

and best disposal methods lead to less improper disposal methods which cost all taxpayers more. Groups who knowingly and deliberately distort facts and provide false information should be treated similarly to those who illegally pollute the environment. We need to logically and impassionately select the best processes for waste management if we hope to provide reasonable protection of our health and the environment.

* These comments are strictly those of the author and do not represent those of any government agency.

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. REFERENCES

L. Theodore, Y. McGuinn, Pollution Prevention Van Nostrand Reinhold, New York City, NY, 1992.

J.D. Lauber, "The. Safe Disposal of Waste by Thermal Incineration" Air and Waste Management Association, International Toxic Substance Conference, Montreal, Canada, April 2, 1992.

Coalition for Responsible Waste Incineration "Reply to Greenpeace's Playing With Fire Report".

E.T. Oppelt, "Incineration of Hazardous Waste, A Critical Review", Journal of the Air Pollution Control Association, May, 1987, pg. 558-586.

P. Costner and J. Thomton, "Playing With Fire: Hazardous Waste Incineration, a Greenpeace Report, Washington, D.C., 1990.

P. Bahouth, Greenpeace, letter to J. Hair, President, National Wildlife Federation, Washington, D.C., February 22, 1990.

G.F. Knapp, News and Views Air and Waste Management Association, August 1992.

L. Theodore, personal notes.

P. ,Chrostowski, S. Foster, "Scientific Peer Review of Greenpeace's Position on Hazardous Waste Incineratw Impacts" Report prepared by Clement International Corporation for Laidlaw Environmental $mites. Ltd., March 17, 1992.

U.S. EPA - "Guidance on Setting Permit Conditions and Reporting Trial Bum Results" EPA/625/6- 89/019, Appendix D.

U.S. EPA Region I1 - "Report on Motor Vehicle Emissions," February 8, 1993.

J.M. Berry, C.J. Nichol, "A Survey of Auto Emissions in the Greater Vancouver Region", AWMA - 84th Annual Meeting, Vancouver, B.C., June 16-21, 1991.

G. Carroll, R. Thumau, R. Morninghan, L. Waterland, J.W. Lee, and D.J. Foumier, Jr., "Partitioning of Metals in Rotary Kiln Incineration", Cincinnati, OH, U.S. EPA Hazardous Waste Engineering Research Laboratory, PB90-132812, September 1989.

Radian Corp., "Draft Test Report - A Performance Test on a Spray Diyer, Fabric Filter and Wet Scrubber System" prepared for Office of Solid Waste, U.S. EPA, October 1989. ,

J.J. Santoleri, "Metals Emissions from Hazardous Waste Incinerators" National Incineration Conference, Albuquerque, NM, May 1992, pg. 611-618.

Environmental Protection Agency, 40CFR Parts 260 et al, "Buming of Hazardous Wastes in Boilers and Industrial Furnaces; Final Rule," issued February 21, 1991, effective August 21, 1991.

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- - . 17. U.S. EPA, "Guidance on Metals and Hydrogen Chloride Controls for Hazardous Waste Incinerators,"

EPA 1530-SW-90-004, August 1989.

18. J. Boegel, "Assessment of Residues from Incineration of RCRA Wastes", Action, Incineration, and Treatment of Hazardous Waste. Proceedings of the Thirteenth Annual Research Svmposium. Cincinnati, OH, U.S. EPA Hazardous Waste Engineering Research Laboratory,

Land Disposal, Remedial

EPA/600/9-87/015,. July 1987.

19. U.S. EPA Science Advisory Board, "Report on Liquid Hazardous Wastes by the Environmental Effects, Transport and Fate Committee", April 1985.

20. U.S. EPA Science Advisory Board, "Report of the Products of Incomplete Combustion Subcommittee", EPA-SAB-EC-90-004, October 1989.

21. a. PCB Trial Bum Results for the Occidental Chemical Corporation Liquid Waste Incinerator, Niagara Falls, NY, April 25, 1987, Midwest Research Institute.

b. Hyde Park NAPL Trial Bum Results for the Occidental Chemical Corporation Liquid Waste Incinerator, Niagara Falls, NY, January 19, 1988, Midwest Research Institute.

22. Chemical Analysis Report to Occidental Chemical Corporation, Niagara Falls, NY, February 24, 1993, RCRA Environmental, Inc., Amhurst, NY.

23. L. Theodore, J. Reynolds, Introduction to Hazardous Waste Incineration Wiley-Interscience, NYC, NY 1988.

. 'F: .fl ,., i;

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